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XII. Vegetation (Rules 2,04.10, 2.05.4(2)(e) and 4.15 During the original permit application review the Division reviewed the sections of the permit application pertaining to vegetation baseline information, the re vegetation plan, and the success criteria for revegetated areas. This information can be found in the permit application in Sections 2.3 (pages 2-58 - 2-122), 3.6 (pages 3-51 - 3-70, 3-77 - 3-81, 3-84 - 3-155) 4.4 (pages 4-101 - 4-149) and Appendix D. Several concerns were identified during the course of the permit application review by the Division, The applicant has expressed concern over the applicability of the reference area approach over the life of a mine. To this end, the applicant has established permanent reference areas which measure the total variability of the communities they represent. On an annual basis, the applicant is randomly sampling undisturbed areas of each vegetative community and comparing the data to that collected from the permanent reference areas. By doing this, the applicant proposes to determine whether the hypothetical assumptions associated with the use of reference areas are inherently correct. The applicant has adequately sampled affected and reference areas. The permanent reference area sites are statistically equivalent to the affected areas sampled. A method of evaluating herbaceous cover and productivity based on standards derived from linear regression techniques was originally proposed by the applicant. The Division felt that the linear regression technique proposed was not an appropriate application of the methodology and therefore, stipulated: STIPULATION N0, WITHIN SIX MONTHS OF PERMIT ISSUANCE, THE PERMITTEE AND THE DIVISION WILL DEVISE ACCEPTABLE CRITERIA FOR THE EVALUATION OF REVEGETATION SUCCESS FOR HERBACEOUS COVER AND PRODUCTIVITY TO BE APPLIED TO ALL AREAS RECLAIMED DURING THIS PERMIT TERM. On July 27, 1987, the Division received proposed cover and production standards from Trapper Mining, Inc. The proposed cover standards are based on a cover which will keep soil loss, due to rill and sheet erosion, to less than four tons per acre per year based upon the application of the Universal Soil Loss Equation. These standards call fora 52% effective cover on Range Sites A and B and a 43.6 effective cover on Range Site C. The proposed production standards are based upon the lower confidence limit (with a 951; confidence level) of the historic production means on each range site, utilizing the seven years of data from 1979 to 1985,